RBI Extends FLA Annual Return Filing Deadline to 31st July 2025

The Reserve Bank of India (RBI) has extended the deadline for submitting the Annual Foreign Liabilities and Assets (FLA) Return for FY 2024-25 to July 31, 2025. This extension offers considerable relief to Indian entities involved in foreign investments. All Indian companies, LLPs, partnership firms, and Alternative Investment Funds (AIFs) that have received Foreign Direct Investment (FDI) and/or made overseas investments in any previous year(s) (including the current year) are required to file the FLA Return. This includes entities that maintain foreign assets or liabilities on their balance sheets.

Understanding FLA Return Requirements

The Foreign Liabilities and Assets (FLA) Return is a crucial annual compliance requirement under FEMA 1999 (A.P. (DIR Series) Circular No. 45 dated March 15, 2011). This return serves as a comprehensive reporting mechanism for tracking India's international investment position.

Who Must File the FLA Return?

The Reserve Bank of India (RBI) has mandated the submission of an annual Foreign Liabilities and Assets (FLA) return under FEMA 1999. This requirement applies to all India-resident entities, including companies, LLPs, and other organisations such as SEBI-registered Alternative Investment Funds (AIFs), Partnership Firms, and Public Private Partnerships (PPPs).

• Have received Foreign Direct Investment (FDI) in any financial year
• Have made Overseas Direct Investment (ODI) in foreign entities
• Maintain outstanding foreign liabilities or assets as on 31st March 2025

Key Changes in FLA Filing for 2024-25

For the current filing season, the RBI has made several updates: Entities filing the FLA return for the first time with a revised OID must register on the RBI's FLAIR portal to get new login credentials. AIFs and other Investment Vehicles that didn't register on FLAIR in 2024 need to do so via the User Registration Form. However, these entities cannot submit the FLA return through FLAIR; instead, they must submit the FLA-2025 in Excel format (provided by RBI via email) to surveyfla@rbi.org.in.

Filing Process Through FLAIR Portal

The RBI has digitised the entire filing process through the FLAIR (Foreign Liabilities and Assets Information Reporting) portal. Entities must:

• Register on the FLAIR portal (https://flair.rbi.org.in)
• Generate login credentials using a valid email ID
• Complete the five sections of the return:
  • Section I: Identification Particulars
  • Section II: Financial Details
  • Section III: Foreign Liabilities
  • Section IV: Foreign Assets
  • Section V: Variation Report (auto-populated)

Penalties for Non-Compliance

Non-filing of the FLA Return on or before the due date will be treated as a violation of FEMA, and a penalty clause may be invoked for violation of FEMA. The penalty structure includes: The entity responsible for filing the FLA Return shall be liable for payment of the Late Submission Fee (LSF) of INR 7500, as may be decided by the Reserve Bank, in consultation with the Central Government, for any delays in reporting.

Under Section 13 of FEMA, 1999

If a contravention is quantifiable, a penalty of thrice the sum involved will be levied. If it's not quantifiable, the company will have to pay a penalty of Rs 2,00,000. Additionally, for continuing contraventions, a penalty of Rs 5,000 per day will be applicable.

Revision Process for Filed Returns

The RBI has also clarified the process for revision of a current year's filed FLA return: Entities must first seek approval through the FLAIR portal. After logging in, navigate to MENU > ONLINE FLA FORM > Request Revised FLA Form, select the relevant year, and submit the request.

Conclusion

Extending the FLA Return filing deadline to July 31, 2025, provides entities with additional time to ensure accurate compliance. However, businesses must not treat this as an opportunity to delay preparations. With stringent penalties under FEMA and the critical role FLA data plays in India's economic monitoring, timely and accurate filing remains paramount. Entities should begin gathering necessary documentation, ensuring FLAIR portal registration is complete, and consulting with compliance professionals to avoid last-minute complications and potential penalties.

Author Bio

Editorial Team | in

Setindiabiz Editorial Team is a multidisciplinary collective of Chartered Accountants, Company Secretaries, and Advocates offering authoritative insights on India’s regulatory and business landscape. With decades of experience in compliance, taxation, and advisory, they empower entrepreneurs and enterprises to make informed decisions.